(1) Please explain whether
these Regulations are intended generally (apart from the provision
made for Part IV by regulation 21(1)) to apply not only to United
Kingdom ships but also to non-United Kingdom ships whilst they
are in United Kingdom waters. Compare regulation 3(2) of the corresponding
Regulations for ships of Classes I, II and II(A): S.I. 1998/2514).

Yes, they are intended to apply
also to non-UK ships when in UK waters. The definition of the
Classes of ships means that in the large majority of cases the
ships will always be in UK waters.

(2) Both regulation 8 and
regulation 32(2) require subdivided ships to be subdivided

by bulkheads into compartments
of a length calculated in accordance with Merchant Shipping Notice
MSN 1699 (M) and impose the same requirements as to watertightness
and design for other portions of the internal structure. Please
explain the apparent duplication.

The phrase is a term of art in
naval architecture. Roughly speaking it means that the fact that
water slops about in tanks has to be taken into account.

(4) Regulation 51(3) requires
every ship with multiple propellers to undergo trials to determine
the ability of the ship to manoeuvre with one
propeller inoperative. The corresponding regulation 64(3) refers
to manoeuvrability with one or more propellers inoperative.
Is this distinction intended? If it is, explain why the provisions
differ.

The distinction was not intended.
It should be one or more.

(5) In regulation 73 -

(a) is it intended that contravention
of regulation 25 does not constitute an offence?

(b) is it intended that no
offence is committed by the officer appointed for the

purposes of regulation 23
who reports a door to be closed and locked when it is not in fact
closed and locked? (Compare the corresponding regulation 91(5)).

(c) in paragraph (3) which
creates an offence triable either way, ought not the summary fine
to be expressed by reference to the statutory maximum (as with
the intended reference to that maximum in paragraph
(1))?

(a) Yes. But if gangway doors
are opened other than in an emergency or when, in spite of emergency,
the master considers that opening the doors would put safety at
risk, the offence committed is contravention of regulation 22
or 24 rather than 25.

(b) There should be such an offence.

(c) Yes.

The errors are very much regretted
and will be corrected at the first convenient opportunity.